The Observer – Montevideo
Last week the 77th Congress of the International Fiscal Association, IFA, was held in Lisbon, Portugal. The greatest exponents of international taxation in the world met there with more than 2,000 attendees.
In that instance it did not go unnoticed the decision of the Portuguese government that excluded Uruguay from the gray list of countries with clearly more favorable tax regimes. The decision takes effect from January 1, 2026, communicated by Portugal through Portada No. 292/2025/1.
The Ministry of Foreign Affairs had already highlighted that this is “part of the recognition of Uruguay’s efforts in relation to the best global tax practicesthe fight against tax evasion and improvement of good governance and transparency.”
When consulted, Juan Bonet, Tax specialist, partner of the Bragard study and assistant for Uruguay as rapporteur at the IFA Congress held days ago, highlighted: “the importance of this decision and that, in light of the Double Taxation Agreement in force between Portugal and Uruguay, opens new planning and investment possibilities that could have been postponed due to the situation of Uruguay’s inclusion on the list”.
The expert added that he had received “very important queries from representatives of Portuguese companies and colleagues about the possible synergies of this in matter of Portuguese investment in Uruguay“.
For his part, Bruno Arez, partner of the firm Eversheds Sutherland Portugal, highlighted the importance of this decision, pointing out that “The exclusion of Uruguay from the list eliminates the restrictions that until now affected operations between Portugal and Uruguaywhich, added to the existence of the Convention to Avoid Double Taxation, allows the country to consolidate itself as a strategic platform for the internationalization of Portuguese groups in their investments in South America”.
Ares added that “in the same way, Portugal once again positions itself as a natural gateway to Europe for investments of Uruguayan origin”.
Finally, the expert noted that “this also opens new opportunities for legitimate estate planning for Uruguayan families seeking to establish themselves or diversify investments in Europe, reinforcing Portugal’s position as an attractive destination for international residence and wealth management.
